CBA committee backs staff plan to require regulatory-review CE within six months of licensure; minutes approved

The California Board of Accountancy Committee on Professional Conduct on Nov. 22, 2024 heard a staff presentation on proposed changes to continuing education rules and the regulatory review continuing education course for newly licensed certified public accountants.

Sarah Benedict, manager of the license renewal and continuing competency unit, said the recommendation responds to a June 2023 Department of Consumer Affairs Office of Professional Examination Services review that found most of the professional ethics (PETH) exam duplicated the uniform CPA exam and that the remaining California-specific material could be handled through continuing education rather than a separate prelicensure test. Benedict said the board adopted partial rule changes in November 2023 that took effect July 1, 2024, and the work group has since focused on a longer-term approach to replace the prelicensure requirement.

"The work group recommended amending the current regulations to require the newly licensed CPAs complete the regulatory review course within 6 months of licensure," Benedict said, and staff proposed clarifying the rule to require completion "within 6 months of licensure or by their first renewal, whichever comes first," so the course is always reported on the first renewal.

Staff proposed several implementation and quality-control changes, including extending course approval terms from two to three years so providers reapply with full materials every three years, allowing a through-course test option for self-study providers (current end-of-course tests exclude true/false and require a 90% score), requiring course content to review continuing education requirements and methods for license renewal and active status, and adding an end-of-course evaluation to collect targeted feedback.

Committee members expressed general support and asked clarifying questions. Member Doug Aguilera thanked staff for removing overlapping definitions from regulation drafts and asked whether the proposed provider survey would be mandatory for licensees to receive CE credit. Benedict responded that "I don't believe that was our intention," indicating staff did not intend the evaluation to be required for credit. Aguilera also warned the six-month requirement could unintentionally create a new enforcement burden similar to widespread confusion over the '20 and 12' CE reporting issue and urged strong outreach to new licensees.

Nancy Corrigan praised the staff recommendation to add clear information on license renewal methods and the distinction between laws and regulations, calling it helpful. Michelle Senter, chief of licensing, said the licensing office recently obtained listserv software that will allow targeted emails to remind licensees of time-sensitive requirements, addressing a prior communications hurdle.

Jason Fox, speaking as a provider representative, said he agreed with staff recommendations and offered logistical help with implementation and outreach, including provider coordination on what the new course model would look like.

The committee approved the July 25, 2024 minutes earlier in the meeting by roll call; the chair declared "The motion carries." No formal rule changes were adopted at the Nov. 22 meeting; staff asked the committee to provide direction so draft regulatory language can be updated for future CBA rulemaking.

Votes at a glance: the committee voted to approve the July 25, 2024 CPC minutes (motion moved by 'Miss Jew,' seconded by Theresa Thompson; roll-call votes recorded by Miss Reid resulted in the chair declaring the motion carried).